Tryg

The Supervisory Board is responsible for the central strategic management and financial control of Tryg and for ensuring that Tryg's business setup is robust. This is achieved by monitoring targets and frameworks based on regular and systematic reviews of strategy and risks.

The Executive Board reports to the Supervisory Board on strategies and action plans, market developments and Group performance, capital requirements and risks, etc. The Supervisory Board holds an annual strategy seminar to decide on and/or adjust the Group's strategy to sustain value creation in the company. The Executive Board works with the Supervisory Board to ensure that the Group's strategy is developed and monitored. The Supervisory Board ensures that the necessary skills and financial resources are available for Tryg to achieve its strategic targets.

The Supervisory Board specifies its activities in a set of rules of procedure and an annual cycle for its work.

The role of the Supervisory Board excl. employee representatives

Size of the Supervisory Board: Number of non-employee representatives

The Executive Board reports to the Supervisory Board on strategies and action plans, market developments and Group performance, capital requirements and risks, etc. The Supervisory Board holds an annual strategy seminar to decide on and/or adjust the Group's strategy to sustain value creation in the company.

The Supervisory Board is regularly informed about the dialogue with investors and other stakeholders. Each year, the Supervisory Board reviews sustainability matters and ensures they are integrated into the company's strategic direction.

Sustainability and ESG are defined as key enablers to support Tryg's 2027 strategy. Under the themes 'Future-fit products', 'Climate action' and 'People at Tryg', ambitious ESG targets have been defined to bolster future business resilience and enhance competitiveness.

Integration of sustainability-related performance in incentive schemes

The sustainability statement references GOV-3 on page 60, however the excerpt provided does not contain substantive content from page 60 regarding the integration of sustainability-related performance in incentive schemes.

Based on the excerpts provided, no specific information is disclosed regarding:

• Which roles are covered by sustainability-linked incentives
• Specific sustainability KPIs tied to remuneration
• Weighting of STI/LTI tied to sustainability
• Performance periods and target structures
• How threshold/target/maximum performance is defined
• Disclosure of payout against sustainability KPIs in the reporting period

The content index on page 71 indicates that GOV-3 disclosure is located on page 60, which is not included in the provided excerpts.

Tryg is the leading non-life insurer in Scandinavia. We are the largest player in Denmark, the third-largest in Sweden and fourth-largest in Norway. Our 6,621 employees provide peace of mind for around 6 million customers and handle approximately 2.2 million claims on a yearly basis.

Business Model and Value Chain

Leading market position

• Market position in Denmark: 1 (12.9% market share)
• Market position in Norway: 4 (24.4% market share)
• Market position in Sweden: 3 (16.5% market share)

Revenue distribution by geography:

• Denmark: 47%
• Norway: 31%
• Sweden: 22%

Business segments:

• Private (68% of insurance revenue): Provides insurance products to private customers in Denmark, Sweden and Norway. Private offers a range of insurance products including motor, content, house, accident, travel, motorcycle, pet and health.
• Commercial (25% of insurance revenue): Provides insurance products to small and medium-sized commercial customers in Denmark, Sweden and Norway. Commercial offers a range of insurance products including motor, property, liability, workers' compensation, travel and health.
• Corporate (7% of insurance revenue): Provides insurance products to corporate customers in Denmark, Sweden and Norway. Corporate offers a range of insurance products including motor, property, liability, workers' compensation, travel and health.

Distribution channels:

• Online • Call centres • Own sales agents • Partner • Franchises • Bancassurance • Car dealers • Real estate agents • Insurance brokers

Tryg's business model is built around providing peace of mind to customers through comprehensive insurance coverage while maintaining strong market positions across Scandinavia.

Tryg maintains regular dialogue with various stakeholder groups:

Shareholders and Investors Tryg's Investor Relations (IR) department maintains regular contact with analysts and investors. Together with the Executive Board, the Investor Relations team organises investor meetings, conference calls and participates in conferences in Denmark and abroad. The Supervisory Board is regularly informed about the dialogue with investors and other stakeholders.

Customers Tryg achieved a customer satisfaction level of 87 in 2024, an improvement of 3 percentage points since 2020. Customer satisfaction remains paramount to Tryg, and the company continues to work diligently to meet and exceed customer expectations. Around 6 million customers are served across Scandinavia.

Employees With 6,621 employees, Tryg maintains focus on employee engagement, diversity and talent retention to deliver on ambitious sustainability targets by 2027.

TryghedsGruppen TryghedsGruppen owns 48.1% of Tryg and contributes to projects that create peace of mind via TrygFonden. In 2024, TrygFonden contributed approximately DKK 680m to these projects. For the ninth consecutive year, TryghedsGruppen paid out a member bonus of approximately DKK 1bn to 1.5m Tryg customers in Denmark.

All stakeholders are provided with comprehensive information through Tryg's website, quarterly reports, investor presentations and regular communications to ensure transparency in the company's position and performance.

Tryg has identified several material impacts, risks and opportunities that interact with its strategy and business model:

Climate-related impacts and opportunities: In a world increasingly impacted by climate change, Tryg offers customers peace of mind, ensuring coverage in the event of claims. Weather events for the full year 2024 were in line with Tryg's annual expectations, with weather claims amounting to 2.4% of insurance revenue compared to the normalised level of approximately DKK 800m annually.

Tryg is dedicated to helping its customers adapt to climate change and prevent claims from happening in the first place. The company has expanded offerings with products that can help customers adapt to climate change, while maintaining focus on minimising the use of resources in the claims handling process.

Emissions reduction: A large part of Tryg's carbon emissions stem from the handling of approximately 2.2 million annual claims. In 2024, Tryg reduced CO2e emissions of 27,825 tonnes in claims handling, exceeding the target of 20,000-25,000 tonnes.

Strategic targets 2027:

• Customer satisfaction target of 83 for the full Group
• Reduce CO2e emissions by 6% per average claim by 2027 compared to 2024
• Adapt 30 product categories, corresponding to 60% of categories in scope for the EU Taxonomy
• Increase straight-through processing for digitally reported claims to over 55%

These material sustainability themes are integrated into Tryg's business strategy 'United Towards '27' under three strategic pillars: Scale & Simplicity, Technical Excellence, and Customer & Commercial Excellence, supported by enablers including sustainability & ESG.

During the current strategy period, Tryg has expanded its offerings with products that can help customers adapt to climate change, while maintaining focus on minimising the use of resources in the claims handling process. 2024 has been a year of preparing for the Corporate Sustainability Reporting Directive (CSRD). Involving different teams, skills and disciplines across the organisation, sustainability & ESG are now integral parts of Tryg's business and customer offerings.

Sustainability and ESG are defined as key enablers to support Tryg's 2027 strategy. Under the themes 'Future-fit products', 'Climate action' and 'People at Tryg', ambitious ESG targets have been defined to bolster future business resilience and enhance competitiveness.

The materiality assessment process involved different teams, skills and disciplines across the organisation to identify material impacts, risks and opportunities related to Tryg's business activities.

Based on the materiality assessment, Tryg has identified the following ESRS topics as material:

• ESRS 2 (General Disclosures)
• E1 (Climate Change)
• E5 (Resource Use and Circular Economy)
• S1 (Own Workforce)
• S4 (Consumers and End-Users)
• G1 (Business Conduct)

The sustainability statement covers these material topics with specific disclosure requirements under each standard. The company has prepared its first CSRD report in accordance with ESRS requirements, involving different teams, skills and disciplines across the organisation.

Transition plan for climate change mitigation

Scope of the plan

Tryg is committed to taking its part in mitigating the impact of climate change and contributing to a low-carbon economy. As a financial sector company, the majority of Tryg's CO2e impacts are indirect and occur in the value chain, e.g. from suppliers and investments.

With approximately 7,600 employees across 32 locations in Denmark, Norway and Sweden, Tryg remains focused on taking the necessary measures to also reduce the climate impact of its own operations by minimising emissions from its offices through energy efficiency, waste reduction and segregation, and changing employees' transportation habits.

Target years and milestones

Tryg has defined climate emissions reduction targets as part of its 2027 strategy. The targets are defined based on best practices and externally available guidance such as relevant manuals from the GHG protocol, Partnership for Carbon Accounting Financials (PCAF) and manuals from the SBTi. As such, although not validated, Tryg has worked to define its targets in line with the Paris Agreement's 1.5°C scenario.

The targets are:

• Scope 1: 42% CO2e emission reductions by 2030 compared to 2023
• Scope 2: 100% annual sourcing of renewable electricity until 2030
• Scope 3: 40% of suppliers (measured by spend) have set Science Based Targets by 2029¹

In addition to these targets based on conclusive scientific evidence, Tryg has defined a target for CO2e emission reductions from claims handling activities and has updated its existing targets related to own operations, waste and business travel. Tryg is not excluded from the EU Paris-aligned Benchmarks.

Alignment with 1.5°C / SBTi validation status

Tryg has worked to define its targets in line with the Paris Agreement's 1.5°C scenario. Although not validated, the targets are based on best practices and externally available guidance such as relevant manuals from the GHG protocol, Partnership for Carbon Accounting Financials (PCAF) and manuals from the SBTi.

Key decarbonization levers

Scope 1

The majority of scope 1 emission reductions will be driven by incentives and policies related to the company car fleet focusing on getting more employees eligible for company cars to choose an electrical vehicle. A minor part of scope 1 stems from natural gas heating, which is still used in one minor building in Denmark. Focus will be on shifting the heating source to district heating or heat pumps, for example.

Scope 2

Sourcing renewable electricity is dependent on various issues, such as authority approval, dialogue with the landlord and physical condition of the site. For the remainder, Guarantee of Origin certificates will be applied.

Scope 3

Supplier engagement is a prerequisite for driving progress in the supply chain. Across all its suppliers, Tryg will advocate and push for them to commit to SBTi. The more companies that commit to Paris-aligned targets, the larger the climate impact. Additionally, Tryg will continue its focus on more resource-efficient claims handling through repairs and reuse, leading to CO2e emission reductions.

Governance and approval

Senior-level approval of transition plan: The transition plan is approved by the Sustainability & ESG Board. The targets and underlying roadmaps are an integral part of Tryg's 2027 strategy and as such ultimately approved by the Supervisory Board.

Governance and roadmaps are defined for all new targets to ensure ownership and progress across the organisation as of 2025.

Additional targets

In addition to the Scope 1, 2, and 3 targets, Tryg has defined:

• 6% CO2e emissions reduction per average claim (driving development towards 2027)
• 100% of premiums from commercial extractors and producers of fossil fuels covered by green transition plans by 2027
• Reducing the consumption of new materials in claims handling by 10% per average claim
• 30 product categories aligned with the EU Taxonomy technical screening criteria (corresponding to 60% of all product categories in scope)

Total GHG emissions and targets table

¹ Suppliers in scope for the target are all Tryg's direct and indirect suppliers, covering the full Scope 3 categories 1, 2 and 11.

Paris-aligned Benchmarks exclusion

Tryg is not excluded from the EU Paris-aligned Benchmarks.

Fossil fuel engagement

As of 2025, Tryg will start pushing for green transition plans and greenhouse gas emission reduction targets for certain activities in the fossil fuel sector. This is a first step towards Tryg proactively encouraging and monitoring its customers' plans for decarbonisation. The target is 100% of premiums from commercial extractors and producers of fossil fuels covered by green transition plans by 2027.

Policies related to climate change mitigation and adaptation

Tryg does not disclose a named climate change policy in the provided excerpts. However, the company describes its climate commitments and approach through its strategic framework and targets.

Climate Commitments and Strategic Approach

Tryg has integrated climate change mitigation and adaptation into its 2027 strategy through three focus areas:

• Future-fit products: Supporting customers in adapting to climate change and preventing its impacts
• Climate action: Driving the green transition throughout the value chain
• Empowering people: Achieving sustainability targets by leveraging all talent

Targets:

• Scope 1: 42% CO2e emission reductions by 2030 compared to 2023
• Scope 2: 100% annual sourcing of renewable electricity until 2030
• Scope 3: 40% of suppliers (measured by spend) have set Science Based Targets by 2029
• 6% CO2e emissions reduction per average claim
• 100% of premiums from commercial extractors and producers of fossil fuels covered by green transition plans by 2027

Governance:

• The transition plan is approved by the Sustainability & ESG Board
• Targets and underlying roadmaps are integral to Tryg's 2027 strategy and ultimately approved by the Supervisory Board
• Governance and roadmaps are defined for all new targets to ensure ownership and progress across the organisation as of 2025

Alignment with standards: The targets are defined based on best practices and externally available guidance including:

• GHG Protocol manuals
• Partnership for Carbon Accounting Financials (PCAF)
• Science Based Targets initiative (SBTi) manuals
• Although not validated, Tryg has worked to define its targets in line with the Paris Agreement's 1.5°C scenario

Implementation approach:

• Supplier engagement to push for SBTi commitments
• Focus on resource-efficient claims handling through repairs and reuse
• Use of technical capabilities for pricing and analysis, reserves and claims forecasting, underwriting risks and reinsurance
• Annual renewal of insurance policies to ensure long-term climate impact mitigation through price adjustments
• Forward-looking scenario-based approach accounting for climate impact incorporated into product pricing where relevant
• Advice to customers on protecting assets from environmental and climate-related damage
• Collaboration with local authorities to prevent damage through data sharing

Actions and resources in relation to climate change policies

Climate Action - Decarbonising the value chain and focus on repairs and reuse in claims handling

Scope: Own operations and value chain (Scope 1, 2, 3)

Time horizon: 2027 and 2030 targets

Actions:

1. Transition away from natural gas and change in company car fleet (Scope 1)

• Target: 42% CO2e emissions reduction in Scope 1 by 2030 (24% by 2027)
• Baseline: 1,120 tCO2e (2024)
• Decarbonisation lever: Internal policies and incentives towards electrical vehicles
• Resources: Not quantified

2. 100% annual sourcing of renewable electricity (Scope 2)

• Target: 100% annual sourcing of renewable energy by 2027 and 2030
• Baseline: 100 tCO2e (2024)
• Decarbonisation lever: Compensate by purchasing GO (Guarantee of Origin certificates)
• Resources: Not quantified

3. Energy-efficiency improvements

• Target: CO2e reduction from energy consumption (location-based): 7.5% by 2027, 15% by 2030
• Baseline: 978 tCO2e (2024)
• Resources: Not quantified

4. Waste segregation (Scope 3, C5)

• Target: CO2e reduction from waste: 3% by 2027, 6% by 2030
• Baseline: 112 tCO2e (2024)
• Resources: Not quantified

5. Reduction in business travel, air travel (Scope 3, C6)

• Target: 2% by 2027, 5% by 2030
• Baseline: 1,684 tCO2e (2024)
• Decarbonisation lever: Internal policies, online meeting and collaboration platforms
• Resources: Not quantified
• Note: In 2024, achieved 49% reduction vs. baseline

6. Supplier engagement - Science Based Targets alignment (Scope 3)

• Target: 40% of suppliers (by spend) aligned with SBTi targets by 2029
• Decarbonisation lever: Supplier engagements and Terms and conditions
• Resources: Not quantified
• Note: First time reporting year-end 2025

7. Repairs and reuse in claims handling (Scope 3, C1, C2, C11)

• Target: 6% CO2e emissions reduction per average claim by 2027
• Decarbonisation lever: Repair floors, recycle car parts, refurbish mobile phones while maintaining highest standards of safety and quality
• Resources: Not quantified
• Note: Covered by transversal intensity target across C1, C2 and C11

8. Reduction in use of new materials per average claim

• Target: 10% reduction by 2027
• Decarbonisation lever: Repairs and reuse in claims handling
• Resources: Not quantified
• Note: Break from 'use-and-throw-away' culture, promote circular approach

9. Avoided emissions from more sustainable claims handling

• 2024 result: 27,825 tCO2e avoided emissions
• 2024 target: 20,000–25,000 tonnes CO2e
• Resources: Not quantified

10. Increase in sustainable spend

• 2024 result: 47% increase
• 2024 target: 80% increase
• Baseline: 0% (2020)
• Resources: Not quantified

Future-fit Products - Supporting customers in adapting to climate change

Scope: Downstream value chain (customers)

Time horizon: 2027

11. EU Taxonomy-aligned product categories for climate adaptation

• Target: 30 product categories aligned with the EU Taxonomy by 2027, corresponding to approximately 60% of all product categories in scope for climate adaptation
• Current status: 13 product categories (2024)
• Resources: Not quantified
• Actions include:
  • Proactive support and effective solutions for climate-related claims prevention
  • Leveraging extensive data and forecasting to understand, price and anticipate impacts of climate change
  • Warnings and preventative information through cooperation with SMHI (Swedish Meteorological and Hydrological Institute) to warn clients in areas at risk of storms
  • AI feature to warn clients in specific areas with identified increase in specific claim types
  • Support for summer swimming classes for children (Sweden)

Commercial Customers - Green Transition Plans

Scope: Downstream value chain (commercial customers)

Time horizon: 2027

• Target: 100% of premiums from commercial extractors and producers of fossil fuels covered by green transition plans by 2027
• Resources: Not quantified
• Approach: Take proactive role in pushing customers involved in extraction and production of fossil fuels towards green transition

Technology Solutions for Climate Adaptation

Actions taken in 2024:

• Denmark: AI assistant Felix offers tailored suggestions to customer advisors in real time during telephone conversations
• Norway: AI and advanced voice analytics for training and coaching customer advisors
• Sweden: Cooperation with SMHI enabling warnings to clients in areas at risk of storms and tips on extreme weather preparation

Overall Climate Targets Summary

Resources allocated: While specific financial allocations (capex/opex) are not disclosed, actions are integrated across Tryg's 2027 strategy pillars: Customer & Commercial Excellence, Scale & Simplicity, and Technical Excellence. Sustainability and ESG are defined as key enablers supporting the 2027 strategy.

Tryg has set ambitious climate targets as part of its 2027 strategy:

CO2e emissions reduction target: Tryg has set a target of reducing CO2e emissions by 6% per average claim by 2027 compared to 2024. This target addresses Tryg's main emission footprint through its claims handling activities.

2024 achievements: In 2024, Tryg reduced CO2e emissions of 27,825 tonnes in claims handling, exceeding the target of 20,000-25,000 tonnes. The fulfilment of this target was made possible through several initiatives for increasing repairs and the use of reused materials in claims handling.

Product adaptation target: Tryg targets adapting 30 product categories, corresponding to 60% of categories in scope for the EU Taxonomy, to help customers adapt to climate change and implement prevention measures.

Energy consumption and mix

Energy consumption disaggregated by source (E1-5)

ⁿ Limited assurance in 2023

Scope and methodology

Own operations (E1-5_01): Based on utility activity data from meter readings and supplier documentation. Locations under 750 m² based on average estimation per m². Q4 includes estimations due to delays in receiving invoices; comparison control performed when actual data available, with deviations assessed against material thresholds.

Fossil sources (E1-5_02): Includes company cars (fossil fuel) in Denmark and Sweden (driving consumption from leasing partner data), natural gas (meter readings and supplier documentation), and diesel for emergency generators. Norway has no company cars.

Nuclear sources (E1-5_03): Tryg's energy consumption consists of an energy mix based on Nordic energy co-operation, which includes nuclear sources among others. Tryg has no direct nuclear sources.

Renewable sources (E1-5_06): Fuel consumption from renewable sources comes from natural gas containing a percentage of biogas. Percentage share from https://groengas.dgc.dk/ (2022 figures).

Purchased renewable energy (E1-5_07): Calculation based on market-based emission factors as the most conservative and representative approach.

Renewable percentage (E1-5_09): Indicates how much of total consumed energy comes from renewable energy sources.

Electricity coverage: Tryg covers 100% of its electricity consumption through Guarantee of Origin certificates. In 2024, converted from natural gas to district heating at Kolding site in Denmark, leaving only one minor site using natural gas.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1: Gross direct GHG emissions

Note: 2024 increase due to inclusion of Swedish company cars. Scope 1 consists of emissions from company cars in Denmark and Sweden and stationary combustion (natural gas and diesel for emergency generators).

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Scope 2: Gross indirect GHG emissions from purchased energy

Note: Scope 2 includes indirect emissions from purchased electricity and heating/cooling at locations where Tryg has operational control. Tryg covers 100% of electricity consumption through Guarantee of Origin certificates.

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Scope 3: Gross indirect GHG emissions from value chain

Scope 3 methodology notes:

• C1, C2, C11: Based on spend data from procurement system using emission factors from carbon accounting system. First-time disclosure in 2024.
• C3: Calculated by multiplying total facilities and transport consumption by relevant emission factors.
• C5: Based on invoices from waste management facilities.
• C6: Data sourced from external business travel management systems and expense system, using hybrid activity and spend data.
• C15: Emissions from covered bonds calculated using key figures (CO2e per million DKK) from Capital Market Partners for Danish issuers. Swedish and Norwegian issuers not yet covered.

Excluded categories:

• C4 (Upstream transportation and distribution): No physical goods
• C7 (Employee commuting): High uncertainty, under assessment
• C8 (Upstream leased assets): Not applicable
• C9 (Downstream transportation): No physical products
• C10 (Processing of sold products): Not applicable
• C12 (End-of-life treatment): Not applicable
• C13 (Downstream leased assets): Not applicable
• C14 (Franchises): Not applicable

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Total GHG emissions

Note: Total figures 2019-2023 based on narrower scope (company cars DK, natural gas, district heating, waste, air travel only). 2024 figures include expanded Scope 3 categories 1, 2, 3, 11, 15.

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GHG intensity

Note: Intensity based on insurance revenue of DKK 38,596m (2024).

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Energy consumption

Methodology: Based on utility activity data from meter readings and supplier documentation. Locations under 750 m² estimated based on average per m². Q4 includes estimates due to invoice delays; deviations assessed against materiality thresholds when actual data available. Biogas percentage from https://groengas.dgc.dk/ (2022 figures). Renewable share calculated using market-based emission factors.

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Avoided emissions from claims handling initiatives

Note: Separate reporting of avoided emissions from specific repair/reuse initiatives in claims handling (motor repairs, building preservation, etc.). Not included in Scope 1-3 inventory.

In a world increasingly impacted by climate change, Tryg offers customers peace of mind, ensuring coverage in the event of claims. Weather events create both risks and opportunities for Tryg's business:

Weather-related claims impact: Weather events for the full year 2024 were in line with Tryg's annual expectations. The first half of 2024 brought severe weather challenges to customers, with heavy rainfall impacting Denmark and Norway experiencing a harsh winter with substantial snowfall. Both events caused property damage and interfered with everyday life.

Financial impact: Weather claims amounted to 2.4% of insurance revenue in 2024, with historical data suggesting weather-related claims will amount to approximately DKK 800m annually. The insurance service result in 2024 included worse-than-normal weather claims.

Adaptation and opportunities: As a leading insurance provider in Scandinavia, Tryg is dedicated to supporting society and assisting insured clients in recovering from weather events. Tryg has expanded its offerings with products that can help customers adapt to climate change, creating opportunities for growth in climate-adapted insurance products.

Policies related to resource use and circular economy

The company references ESRS E5-1 on page 88 of the sustainability statement, but the excerpts provided do not contain the actual disclosure content for this data point. Only the index/table of contents is included, which indicates that E5-1 policies are discussed on page 88.

Without access to page 88 content, the specific policies related to resource use and circular economy cannot be extracted or documented.

Tryg will develop and expand practices for repairs and the recycling of materials through close collaboration with suppliers. The company has a continued focus on minimising the use of resources in the claims handling process.

Claims handling initiatives: A large part of Tryg's carbon emissions stem from the handling of approximately 2.2 million annual claims. In 2024, Tryg is pleased to have reduced CO2e emissions of 27,825 tonnes in claims handling through several initiatives for increasing repairs and the use of reused materials in claims handling.

Circular economy practices: Tryg's approach includes initiatives related to increasing repairs and the use of reused materials in claims handling, supported by close collaboration with suppliers to develop and expand these practices.

Tryg has set a target of reducing CO2e emissions by 6% per average claim by 2027 compared to 2024, with focus on continuing circular economy practices through:

• Increasing repairs in claims handling
• Expanding the use of reused materials
• Close collaboration with suppliers
• Minimising resource use in claims handling processes

In 2024, Tryg achieved a reduction of 27,825 tonnes CO2e from its claims handling processes, exceeding the target of 20,000-25,000 tonnes through initiatives for increasing repairs and the use of reused materials.

E5-4 Resource Inflows

Tryg reports resource inflows specifically related to its claims handling process, focusing on the main resource-intensive business areas of motor and building claims. As a non-life insurance company, Tryg has no critical raw materials or rare earths according to the European Critical Raw Materials Act definition.

Resource Inflows Table

Percentage of Secondary Materials

Based on the reported figures:

• Secondary/recycled materials: 457 tonnes out of 5,759 tonnes total = 7.9% of total resource inflows
• Primary/new materials: 5,302 tonnes = 92.1% of total resource inflows

Scope and Data Collection

In 2024, Tryg introduced reporting on resource inflows from motor claims, where data is available. Figures for resource inflow from building claims will be included as of 2025.

Data is collected based on different systems in Denmark, Norway and Sweden. All systems collect information on the use of spare parts (in tonnes), and a suitable weight factor is derived from the system named Märkesdemo.

Identifying and reporting on reused spare parts are based on the same method as the reporting of new spare parts, but using categories regarding reuse and recycle.

Context

Tryg's resource inflows are limited to the claims handling process. The company has set a strategic target to reduce the use of new materials per claim by 10% by 2027 (baseline 2024), focusing on increased use of circular materials or repair techniques and minimisation of primary raw material use.

Resource outflows

Tryg reports on resource outflows in the context of its own operations and claims handling processes.

Products and Services (Insurance)

As an insurance company, Tryg does not manufacture physical products. However, through its claims handling process and supplier management, Tryg influences resource circularity:

• Repair and reuse initiatives: Tryg has implemented initiatives across motor, building, and content claims focusing on repairs and use of recycled/reused materials rather than replacement with new items.
• Avoided emissions from sustainable claims handling: In 2024, Tryg avoided 27,825 tonnes CO2e through repair, reuse, and recycled materials in claims handling.
• Sustainable spend: 47% of claims spend in 2024 was classified as sustainable (repairs, reused materials, emission-saving initiatives).

2027 Target

Tryg has set a target to reduce the use of new materials per average claim by 10% by 2027 (baseline 2024). This intensity target aims to increase use of circular materials and repair techniques while minimizing primary raw material use.

Specific Initiatives

Motor claims: Established practices for repairing windshields, car bumpers, rims, car body parts, and headlights. Auto repair shops increasingly use recycled spare parts. In Norway, partnership with car repair chains enables use of reused parts (doors, bumpers) even on cars less than 5 years old.

Building claims: Initiatives include repairs of doors and windows, spot repairs of parquet floors, preservation of foundation walls and building materials (concrete, tiles), and reuse of tiles.

Other: Repairs of phone screens, reduced transport needs through remote monitoring and online consultations.

Tryg published a catalogue 'Handled with care' describing specific repair/reuse initiatives for suppliers.

Waste

Waste Management Approach

Tryg manages internal waste in accordance with the EU waste hierarchy: preparing for reuse, recycling, other utilization, and disposal.

Reuse practices: Tryg donates or resells excess office furniture (desks, cabinets, bookcases) to charity organizations or at auctions.

Waste sorting equipment: New waste handling equipment installed at all Danish locations enables better sorting into fragments and ensures reusable materials are reused.

IT waste: Tryg places demands on suppliers handling electronic waste to comply with the EU WEEE Directive and RoHS Directive, resulting in the majority of usable IT equipment being sold on or recycled. As of 2025, Tryg expects to expand waste reporting to include IT waste sent to reuse.

Local operations: In Sweden and Norway, local landlords are responsible for optimal sorting and reuse solutions, with Tryg contributing proactively.

2024 Waste Performance

CO2e emissions from waste were reduced by 20% compared to the base year (2019: 140 tCO2e, 2024: 112 tCO2e).

Quantitative Waste Data (2024)

Accounting Principles

E5-5_07 Total Waste generated: Waste is generated in own operations and based on invoices from waste management supplier.

E5-5_08 - E5-5_09 Recovery operation and treatment type: Waste is diverted from disposal and sorted into hazardous and non-hazardous waste according to waste categories, recovery operation types and treatment types, which include incineration, landfill and other disposal operations.

E5-5_10 Non-recycled waste: Disposal waste that cannot be recycled and is sent to landfill.

E5-5_11 Percentage of non-recycled waste: The percentage of non-recycled waste of the total amount of waste generated. Tryg aims to have no non-recycled waste.

E5-5_15 Total amount of hazardous waste: Consists of various chemical substances, fluorescent tubes, batteries and similar materials used in facility operations. Tryg continually tries to minimize this waste fraction.

E5-5_16 Total amount of radioactive waste: Tryg has no radioactive waste.

Policies related to own workforce

Tryg discloses four policies related to its own workforce under ESRS S1-1:

Sustainability policy

Scope: All employees

Key content / principles:

• Guides the processes for fulfilling the sustainability strategy and legal requirements
• Adheres to public commitments such as the UN Global Compact and the UN Sustainable Development Goals
• Outlines Tryg's commitment to respecting internationally recognised human rights and the core conventions of the International Labour Organization (ILO)
• Guides the overall commitment to create a company culture where everyone is treated with equal dignity
• Outlines commitment to ensuring Tryg does not contribute or be linked to adverse impacts on human and labour rights in its own operations, through its products and services, customers and business relations, and in the supply chain

Links to international standards:

• Supports the UN Guiding Principles on Business and Human Rights
• Supports the OECD Guidelines for Multinational Enterprises
• References core conventions of the International Labour Organization (ILO)
• UN Global Compact
• UN Sustainable Development Goals

Monitoring implementation:

• Continuous assessment of relevant data and insights, such as employee or whistleblower cases and employee engagement and pulse surveys, as part of due diligence to identify actual and potential adverse impacts on human and labour rights

Human and labour rights policy

Key content / principles:

• Addresses commitment to respecting human and labour rights
• Continuously works to identify, prevent and mitigate risks of adverse impacts on human and labour rights both internally and across the value chain

Links to international standards:

• Supports the UN Guiding Principles on Business and Human Rights
• Supports the OECD Guidelines for Multinational Enterprises

Note: Due to limited exposure, there is no workplace accident prevention policy or management system in place. Tryg's Norwegian branch is subject to the Norwegian Transparency Act.

Tryg's Code of Conduct (CoC)

Scope: All employees and other parties acting on Tryg's behalf

Governance:

• Each year, all employees complete CoC training and take a test to confirm their understanding of its principles
• Part of the onboarding for new employees
• Any violations of the CoC may have consequences for employment

Key content / principles:

• Addresses all key issues employees and other parties acting on Tryg's behalf must familiarise themselves with and comply with in their interactions with customers, colleagues, competitors, suppliers and other stakeholders
• Expectations include:
  • Contribute to promoting equal opportunities and safe working conditions for all colleagues
  • Create a safe and pleasant working environment where it is expected that employees take action against behaviour that may be experienced as offensive
  • Refrain from discrimination of employees based on gender, age, disability, sexual orientation, beliefs, religion, skin colour, political views or national, social or ethnic origin
  • Be aware of and try to reduce stereotypes and prejudices
  • Support shared responsibility to respect human rights
  • Be aware of and express concerns about actual or suspected negative impacts on human rights
• For managers:
  • Acting as role models to uphold high moral and ethical standards
  • Actively ensuring that their employees are aware of Tryg's rules and safeguards
  • Taking action against inappropriate behaviour

Links to international standards:

• Based on the UN Global Compact principles
• Based on UN Convention against Corruption

Monitoring implementation:

• Annual mandatory e-learning and testing for all employees
• Employees expected to report any concerns about non-compliant conduct, or actual or suspected lack of respect for human and labour rights via the intranet, employment contract and annual Code of Conduct training
• Whistleblower mechanism available

Policy and target for the underrepresented gender

Key content / principles:

• Addresses gender diversity and representation
• Initiatives, goal setting and continuously monitoring developments
• Gender-neutral remuneration policy striving for equal pay
• Extraordinary pool to increase gender pay equality
• Parental leave policy: every parent, regardless of gender or relation, is entitled to 25 weeks of paid parental leave (Denmark)

Monitoring implementation:

• Regular data analyses to understand pay differences and their root causes
• Preparing for EU pay transparency directive
• Continuously working on identifying and reducing pay gaps
• Introduction of job architecture with specific job levels and salary packages (June 2024)

Public availability

The excerpts do not specify URLs or locations where these policies can be accessed publicly.

Additional governance and monitoring

HR department: Has operational responsibility for ensuring adequate measures for employee-related impacts. One person has dedicated responsibility for advancing the diversity and inclusion agenda across Tryg, with responsibility and resource use decentralised across the organisation.

Whistleblower scheme: Available via external websites and intranet for reporting suspected violations, discrimination, human rights violations, harassment or violations of the Code of Conduct. Reports can be made anonymously. Handled by whistleblower unit composed of Head of Group Compliance, Legal Director, and Chairman of Tryg's Audit and Risk committee.

Employee engagement survey: Used to ensure close alignment and assess inclusion and diversity metrics.

Taking action on material impacts on own workforce

Training programme for advisors

Action description: Training programme for advisors to improve customer service and sales performance.

Outcomes achieved:

• Nearly 60% of advisors improved customer satisfaction scores
• 40% of advisors boosted sales
• Programme earned Tryg two national awards: first place in national response time championship and Customer Service Award in insurance category

Scope: Own operations

Resources: Not quantified

Claims handler training programme

Action description: Regular internal training programme enabling claims handlers to handle claims in accordance with applicable laws, including after large-scale natural disasters.

Scope: Own operations

Resources: Not quantified

Annual employee training on business ethics and compliance

Action description: Mandatory training covering Code of Conduct, anti-corruption and bribery, whistleblower procedures, business ethics and practice, and IT security.

Scope: Own operations (permanent and temporary employees)

Target group: 100% of functions-at-risk covered by training programmes; mandatory for all Tryg employees

Resources: Not quantified

Privacy and cyber security training

Action description: Mandatory e-learning and training programmes to raise awareness on privacy and cyber security, addressing the human factor in data processing and incident prevention.

Scope: Own operations

Resources: Not quantified

AI training and awareness initiatives

Action description: Training and internal awareness programmes focused on AI governance, development and deployment of AI solutions. Established AI Advisory Board to ensure adherence to principles of thoughtfulness & accountability, fairness, transparency, privacy & data protection.

Focus areas for 2025: Training and internal awareness

Scope: Own operations

Resources: Not quantified

Guidewire cloud implementation

Action description: Implementation of Guidewire cloud platform across Tryg to enable claims organisation to share knowledge and create more efficient and scalable solutions.

Scope: Own operations (cross-country)

Resources: Not quantified

Note: Specific resource allocations (financial and non-financial) are not disclosed. The company notes: "Due to the diverging and cross-cutting disciplines associated with managing material impacts towards customers, it is currently not possible to identify the specific resource allocations. This will be further investigated over the coming years."

Characteristics of non-employees in the undertaking's own workforce

Total non-employee workers

Methodology

Tryg's non-employees are people not employed or salaried by Tryg. The global employment type 'External' is used for registering non-employee workers.

The metric received limited assurance in 2023.

Collective bargaining coverage and social dialogue

Collective bargaining coverage metrics

Social dialogue

Engagement with trade unions

To facilitate dialogues across trade unions and employee organisations, Tryg has works and communication committees at the regional and Nordic level. The purpose of the committees is to promote mutual understanding and acceptance through open dialogue and information exchange across the organisation. The committees are composed of members of the Executive Board, HR leadership and employee and union representatives.

Among topics discussed in 2024 were: Organisational changes, downsizing the organisation, changes in terms and conditions related to workforce reduction, changes to employee-related policies, employee engagement, career development and diversity and inclusion initiatives.

Accounting principles

S1-8_01 Percentage of total employees covered by collective bargaining agreements: Employees that have a collective bargaining agreement divided by headcount per country. There is a total of seven different collective bargaining agreement across Tryg.

S1-8_06 Employees covered by workers' representatives: The total percentage of employees covered by workers' representatives split by country level due to different legislation across Denmark, Norway and Sweden.

Diversity metrics

Gender distribution at management levels

*Target for June 30, 2026

Supervisory Board gender distribution

Tryg's Supervisory Board has three of nine (33%) non-employee elected members being women. The gender distribution is considered equal under Danish legislation.

Employee age distribution

Total workforce gender distribution

Employment types by gender (2024 headcount)

Accounting principles

Gender distribution, all management levels (headcount): The number of employees at management level is the year-end headcounts who are employed in a management position during the last month of the reporting period. A manager must be an 'active' employee with the employment types of either 'permanent' or 'temporary'. The indicator includes Tryg's four levels of management.

S1-9_02 Gender distribution, top management level: Gender distribution at the upper level in Tryg called 'Top management', which consists of 'Senior Vice President', 'Vice President' and 'Executive Board'.

Gender distribution, director level: Gender distribution on the second management level, the director level, is based on job level or role.

Gender distribution, the other level of management: This indicator is defined according to BEK no. 503 Section 143 (2) of 23/05/2024. It is two management levels below the Supervisory Board. The first level is the Executive Board and persons who are organisationally on the same level as the Executive Board. The second level is managers with staff responsibilities reporting directly to members of the Executive Board.

S1-9_03 – 05 Employee age groups (headcount): The age groups are calculated at the end of the reporting period and include all headcounts in Tryg. The age groups are >30, 30-49 and 50+ years.

Gender: Gender is specified by the employees themselves.

Country distribution: Denmark: 3,743; Norway: 1,492; Sweden: 2,352.

Limited assurance obtained for 2023 data marked with 'n'.

Training and skills development metrics

Performance and career development reviews

Breakdown by gender (number of employees):

Average training hours

Average training hours by gender:

Methodology notes

• S1-13_02: Percentage calculated as total number of employees that have participated in development reviews divided by the total number of employees (permanent) in Tryg minus employees not in scope for career development and training (e.g. students). Figures are managed in Tryg's global HR system.
• S1-13_03: Number of employees that have participated in regular performance and career development reviews, broken down by gender.
• S1-13_04: Only includes mandatory compliance training. Reported as an average per person and split by gender. Figures are managed in Tryg's three learning platforms.

Health and safety metrics

ESRS S1-14 (S1-13) disclosure status

Tryg's sustainability statement index (p. 130) explicitly marks ESRS S1-14 (a), (b), (c) and (e) as "Not material":

• Number of fatalities and number and rate of work-related accidents paragraph 88 (b) and (c): Not material
• Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e): Not material

No quantitative health and safety metrics (coverage percentage, fatalities, recordable injury rates, lost-time rates, or days lost) are disclosed in the 2024 sustainability statement.

Narrative disclosure

The document contains references to health and safety governance:

• Employees can raise concerns with their direct manager, staff representative, occupational health and safety representative, HR, or use the anonymous whistleblower mechanism (p. 108)
• For commercial customers, Tryg has developed 'Tryg på Arbejde', a risk management concept focusing on occupational injuries, using classical risk analyses and data from wearables to prevent work-related injuries (p. 118)

However, no quantitative metrics for Tryg's own workforce are provided.

Work-life balance metrics

Parental leave entitlement and uptake

Tryg Denmark has a parental leave policy where every parent, regardless of gender or relation, is entitled to 25 weeks of paid parental leave.

Male employee parental leave uptake:

• 2022: Average of 8.2 weeks
• 2024: Average of 17.22 weeks

Gender-disaggregated data

No specific data is disclosed on:

• Percentage of employees entitled to family-related leave by gender
• Percentage of entitled employees who took family-related leave by gender
• Return-to-work rate after parental leave by gender

The disclosure focuses on the policy entitlement (25 weeks for all parents) and the average weeks taken by male employees specifically, showing a doubling of male uptake since the policy's implementation in 2022.

Compensation metrics

Pay gap

Tryg reports gender pay gaps by country for 2024:

Tryg has a gender-neutral remuneration policy and strives for equal pay. However, it is acknowledged that Tryg has not yet accomplished a complete gender pay balance. The company works purposefully to improve data and analyses to better understand where there are differences as well as their respective root causes.

Tryg is currently preparing for the EU pay transparency directive and is continuously working on identifying and reducing pay gaps within the organisation. In June 2024, Tryg introduced a new job architecture with specific job levels and salary packages tied to these. This will enable Tryg to increase fairness and transparency, as salary packages will be based on the role and level of an employee as well as internal and external benchmarks. The job levels are defined by impact and value to the company as well as complexity and degree of responsibility – not on the specific person currently holding the position.

To reduce inequality, Tryg regularly launches initiatives that aim to minimise structural differences. Tryg Denmark has for the past couple of years had a parental leave policy where every parent, regardless of gender or relation, is entitled to 25 weeks of paid parental leave. Since its implementation in 2022, male employees' parental leave increased from an average of 8.2 weeks to 17.22 weeks in 2024.

Tryg has introduced an extraordinary pool to increase gender pay equality.

Remuneration ratio

Tryg reports an annual total remuneration ratio of 21% for 2024 (21% in 2023, 26% in 2019).

Methodology

S1-16_01 Gender pay ratio per country: This indicator measures the average female-male pay gap by calculating the difference between average gross monthly earnings of males and females that are included in the headcount figure.

S1-16_02 Annual total remuneration ratio: Total annual remuneration ratio of the highest paid employees to the median annual total remuneration for all employees excl. the highest paid employee.

The 2023 figures for both gender pay gap and remuneration ratio were subject to limited assurance.

Incidents, complaints and severe human rights impacts

Number of incidents of discrimination

Accounting principles

S1-17_02 Number of incidents of discrimination: Discrimination is a collective term for cases of discrimination, bullying, sexual harassment and other types of harassment that can occur at the workplace. Cases are reported to the HR department through leaders, union or employee representatives or through the Whistleblower hotline.

Actions on discrimination and harassment

Tryg continued its work with diversity, equity and inclusion in 2024 with both ongoing and new initiatives. Actions included:

• Launched a dedicated intranet site covering diversity, equity and inclusion initiatives
• Implemented reflection rooms at largest offices in Denmark, Norway and Sweden for meditation and prayer
• Implemented gender-neutral bathrooms in Denmark
• Enabled employees to identify as female, male, other, or choose not to register in the internal HR system
• Maintained two internal employee resource groups: Rainbow group (LGBTQ+) and Sunflower group (invisible disabilities)
• Supported the Hidden Disabilities Programme

The annual employee engagement survey showed that inclusion questions received the highest scores across all categories, with 91% of employees agreeing "At Tryg, I can be who I am", 91% agreeing "At Tryg, there are equal opportunities for all, regardless of gender, identify, age, ethnicity, sexual orientation, religion, disability, etc.", and 90% agreeing "My direct manager makes sure everyone in the team is heard and feels included."

Grievance mechanisms

Tryg expects suppliers to have a grievance mechanism or similar procedure in place to ensure their employees can voice grievances anonymously and without fear of reprisal. Workers in the value chain can raise concerns through Tryg's anonymous whistleblower hotline, which is available for persons working under the supervision of the management of contracting parties, subcontractors, suppliers and consultants.

Other human rights related matters

ESRS S1-17 Non-respect of UNGPs on Business and Human Rights and OECD Guidelines: Not material

ESRS S2-1 Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines: Not material

ESRS S3-1 Non-respect of UNGPs on Business and Human Rights, ILO principles or OECD guidelines: Not material

ESRS S4-1 Non-respect of UNGPs on Business and Human Rights and OECD guidelines: Disclosed on pages 115

ESRS G1-4 Fines for violation of anti-corruption and anti-bribery laws: Material (postponed)

Policies related to consumers and end-users

The document references ESRS S4-1 (Policies related to consumers and end-users) on pages 114-115, however the provided excerpts do not include the actual content of these pages. The table of contents indicates that S4-1 disclosures exist in the sustainability statement, specifically:

• S4-1 Policies related to consumers and end-users (pages 114-115)
• S4-1 Non-respect of UNGPs on Business and Human Rights and OECD guidelines paragraph 17 (page 115)

Without access to the actual pages 114-115, the specific policies, their scope, governance, content, and monitoring mechanisms cannot be extracted from the provided excerpts.

The excerpts confirm that Tryg has addressed S4-1 requirements and references alignment with:

• UN Guiding Principles on Business and Human Rights (UNGPs)
• OECD Guidelines

However, the detailed policy information is not available in the provided text.

Customer satisfaction initiatives: Tryg achieved a customer satisfaction level of 87 in 2024, an improvement of 3 percentage points since 2020, but slightly below the 2024 target of 88. Customer satisfaction remains paramount to Tryg, and the company continues to work diligently to meet and exceed customer expectations.

Technology solutions for customer experience: During 2024, Tryg launched new technology solutions to enhance the customer experience:

• In Denmark, the AI assistant Felix offers tailored suggestions and input to customer advisors in real time
• In Norway, AI and advanced voice analytics are used to train and coach customer advisors
• In Sweden, the AI assistant Llucia offers faster response to customers with child insurance policies

Customer service improvements: By leveraging advanced speech analytics applied to dialogues between advisers and customers, Tryg has been able to provide tailored training and coaching. As a result, nearly 60% of advisors have improved their customer satisfaction scores and 40% have boosted sales. This earned Tryg two prestigious national awards: first place in the national response time championship and the Customer Service Award in the insurance category.

Product adaptations: Tryg has redesigned several products to better serve customers:

• Child insurance with deeper focus on supporting mental health
• Motor insurance products ranked as best on the market according to Swedish Consumers' Insurance Bureau
• Digital payment solutions through Swish enabling instant claim compensation
• Partnership with LEIA Health to support new parents

Prevention initiatives: Cooperation with SMHI enables Trygg-Hansa to warn clients in areas at risk of storms and share preparation tips. AI features warn clients in specific areas where increased claim frequency is identified.

Tryg has set strategic targets related to customer satisfaction and service excellence:

Customer satisfaction target 2027: For the new strategy period, Tryg has set a customer satisfaction score target of 83 by 2027. Tryg has rebased the customer satisfaction baseline from 87 to 81 due to updated scoring methodology and inclusion of the entire Swedish business.

Straight-through processing target: Tryg aims to increase straight-through processing for digitally reported claims to over 55%, an improvement of 10 percentage points from the baseline of 45%. This target focuses on fast and efficient claims handling through automated processes without manual touchpoints.

Value-creating actions target achieved: Tryg set a target to grow 'value-creating actions' upon logging in online by 40% or above. The company boosted 'value-creating actions' by more than 50% during the strategy period through initiatives like 'My Page'.

Tryg believes that high customer satisfaction and retention rates contribute to lower distribution costs, making the achievement of customer satisfaction targets crucial for realising financial objectives.

Tryg focuses on managing the company in accordance with the principles of good corporate governance and generally complies with the Danish recommendations prepared by the Committee on Corporate Governance. At tryg.com, Tryg has published its statutory corporate governance report based on the 'comply-or-explain' principle for each individual recommendation.

Tryg has adopted a number of policies describing the relationship between different stakeholders. A number of internal guidelines ensure that the disclosure of price-sensitive information complies with legislation and stock exchange codes of conduct.

The company acknowledges that the taxes paid are a significant contribution to sustainable societies in the countries where business is conducted. Tryg Group is a transparent and responsible tax payer, and the tax governance and key tax compliance focus is ensuring that all taxes paid are fair and in accordance with legislation.

Tax Governance: The tax governance approach is embedded in the Tryg Tax Policy inspired by GRI Sustainability Reporting standard #207 regarding tax. The Tax Policy governs all entities in the Tryg Group, all taxes paid by the Tryg Group and, to the extent possible, also investments made by Tryg Group.

The Tryg Tax Policy is overseen by the Chair of the Tryg Risk Committee and reviewed and approved annually by the Executive Board and the Supervisory Board of Tryg. The approach to tax risk management is aligned with the Tryg Group's risk management and actively monitored to ensure that tax positions are within strategic and business objectives.

Total tax contribution: Tryg Group paid a total tax contribution to tax authorities of DKK 6,041m in 2024. Corporate income tax amounted to DKK 1,488m, corresponding to an effective tax rate for Tryg Group of 24%.

Tryg will develop and expand practices for repairs and the recycling of materials through close collaboration with suppliers. The company maintains focus on working with suppliers to implement circular economy initiatives and reduce environmental impact in the claims handling process.

Supplier relationships are integral to Tryg's sustainability efforts, particularly in achieving the target of reducing CO2e emissions by 6% per average claim through increased repairs and use of reused materials in collaboration with suppliers.

Incidents of corruption or bribery

Confirmed incidents

Tryg reported zero incidents or violations concerning corruption or bribery in 2024. The company explicitly stated:

"During 2024, there have been no convictions or violations concerning any of the above themes [anti-corruption and bribery, taxation, fair competition]."

Convictions and fines

No convictions or legal decisions related to corruption or bribery were reported for 2024.

No fines for violations of anti-corruption or anti-bribery laws were disclosed. The reporting notes that metrics on fines for violation of anti-corruption and anti-bribery laws (ESRS G1-4 paragraph 24(a)) are classified as "Material (postponed)".

Disciplinary actions

No information was disclosed regarding employees dismissed or disciplined due to corruption or bribery incidents.

Contracts terminated

No information was disclosed regarding contracts with business partners terminated or not renewed due to corruption or bribery.

Investigation and speak-up mechanisms

Tryg operates a comprehensive whistleblower mechanism available to employees, suppliers, consultants, and customers. The scheme covers:

• Suspected violations of financial regulations or the Anti-Money Laundering Act
• Suspicion of serious offences including financial crime, bribery, fraud or corruption
• Violation of competition rules
• Suspected serious matters directed against employees (physical or psychological violence, discrimination, human rights violations, harassment)
• Violations of Tryg's Code of Conduct

The whistleblower unit consists of the Head of Group Compliance in Tryg A/S, the Legal Director of Tryg Forsikring A/S, and the Chairman of Tryg's Audit and Risk Committee. Reports can be made anonymously. Whistleblowers have special protection against retaliation when reports are made in good faith and within the scope of the Whistleblower Act.

Prevention and training

Tryg maintains a three-line defence governance structure and has established procedures for preventing and detecting corruption and bribery. All employees (100% of functions-at-risk) complete mandatory annual training on the Code of Conduct, which includes anti-corruption, anti-bribery, whistleblower mechanisms, and business ethics.

Business areas with potentially higher risk (customer-facing functions such as claims handling, procurement and contracts) conduct annual risk assessments and participate in specific internal training sessions.

Tryg has defined thresholds for giving and receiving gifts, advantages, representation, and travel, with transparency requirements for both parties' organisations.

Payment practices

Tryg has standard payment terms towards suppliers that are included in the contracts to prevent late payment. The company pays particular attention to its claims suppliers, stating that it makes regular claims to suppliers in its network of claims suppliers, ensuring a steady flow of work while benefiting from an established and known supplier base.

No quantitative metrics are disclosed regarding:

• Average time to pay invoices (days)
• Standard contractual payment terms (in days or by % of payments)
• Number or value of legal proceedings for late payment
• Compliance with prompt payment code

The only related disclosure is that sustainable spend is limited to supplier payments, specifically claims payments for more sustainable solutions, reported as 47% in 2024 and 29% in 2023 (volume adjusted results), though this metric relates to sustainable sourcing rather than payment practices.